CITY OF PH ILADELPHIA Department of Public Health

Environmental Protection Division Air Management Services

InterOffice Memo

To: File

From: Edward Wiener & Kassahun Sellassie

Date: December 5, 2014

Subject: 1997 8-Hour RACT Analysis for Veolia Energy - Edison Station

Introduction:

The Clean Air Act (CAA) requires that moderate (or wo rse) ozone nonattainment areas implement reasonably available control technology (RACT) controls on all major sources of Volatile Organic Compounds (VOC) and Nitrogen Oxides (NOx). Philadelphia County is part of the Philadelphia-Wilmington-Atlantic City moderate ozone nonattainment area for the 1997 8-hour ozone national ambient air quality standard (NAAQS). This document presents the findings of the reevaluation of NOx RACT for the 8-hour ozone standard for this facility.

Company Description:

Veolia Energy Philadelphia - Edison Station owns and op erates a steam generating facility at 908 Sansom Street, Philadelphia, PA 19107. Equipment used at the facility includes four (4) boilers. The facility was formerly named Trigen Philadelphia Energy Company, but adopted the name of its parent company Veolia Energy Philadelphia in

December 2000.

Applicability for NOx and VOC RACT:

Veolia – Edison Station is a major source of NOx due to having potential NOx emissions greater than 100 tons per year but not applicable for VOC due to having potential VOC emissions not greater than 50 tons per year that is applicable to NOx RACT and VOC RACT, respectively. Th e facility is a 1-hour RACT source. As a result of a case-by-case RACT determination, the facility is subject to the RACT plan approval (PA Permit Number 51-4902) dated December 1, 1999, approved into the SIP by EPA on May 29, 1995 (65 FR 78418). All four boilers, Boiler#1, Boiler #2, Boiler #3, and Boiler #4 were covered by 1-hour RACT determination, and thus are required a reevaluation for the 1997 8-hour RACT standard.

Process Descriptions:

Veolia - Edison Station currently has two (2) boilers rated 283 MMBTU/hr (CU01 & CU02-boilers No. 1 and No. 2) and two (2) boilers rated 335 MMBTU/hr (CU03 & CU04-Boilers No. 3 and No. 4). Each boiler is front fired and burns No. 6 oil as the primary fuel and No. 2 oil as the ignition fuel. The emission limitation reduced from 0.50

lb/hr to0.39 lbs/MMBTU. AMS has determined the new lbs/MMB TU limits to be RACT b ecause stack test data has shown the boilers can comply with these limits under existing technology

NOx RACT Evaluation:

In the SIP-approved 1-hour RACT Pl an Approval (PA Permit Number 51-04902) dated December 1, 1999, the boilers were given a combined No. 6 oil limit of 65,526,316 gallons per rolling 12-month period and a combined NOx emission limit 2,195 tons per rollin g 12-month period. Also, each boiler was given a NOx emissions limit of 0.50 pounds per MMBTU of heat input.

The boilers are currently not equipped with NOx controls. The following were considered possible NOx controls for each boiler: Selective Catalytic Redu ction (SCR), Ultra Low-NOx Burners an d switch to natural gas (ULNB with NG), Selective Non-Catalytic Reduction (SNCR), Flue Ga s Recirculation (FGR), Ultra Low NOx Burners without switching fuel type (ULNB), and Burners Out of Service (BOOS) and other combustion modifications.Burners-out-of-service and other combustion modificatio ns for each boiler were determined technologically infeasible because they would cause a reduction in boiler capacity, which could cause issues during peak periods. Selective Catalytic Reduction was determined technolo gically infeasible for each boiler because of space limitations. Selective Non-Catalytic Reduction was determin ed to be technologically infeasible for each boiler because the boilers have frequent load changes and periods of low load operation. ULNB, ULNB with NG, and FGR are considered technologica lly feasible for all boilers.

ULNB are burners designed to create a larger, lower temp erature flame. They redu ce NOx emissions by around

30%.

LNB are burners designed to create a larger, lower temper ature flame. They reduce NO x emissions by around 20%.

FGR takes some of the exhaust gas from the stack and ducts it to the burner. It lowers peak flame temperatures and lowers the oxygen content of the air, reducing NOx emission by around 40%.

ULNB with NG are ULNB that are accompanied by a switch from oil to natural gas. They reduce NOx emissions by around 62%. This option requires the installation of a new gas pipeline and a pressure regulating station.

Boilers #1 and #2:

Boiler # 1and boiler #2 each has a NOx emission limit of 0.50 lbs/MMBTU from the 1-hour RACT determination,

now the emission limitation reduced to0.39 lbs/MMBTU AMS has determined the new lbs/MMBTU limits to be RACT because stack test data has shown the boilers can comply with these limits under existing technology. Each boiler has a Federally enforceable annual 30% capacity limit based on hourly maximum heat input, as listed in Section D. 2 (a)(1) of Title V/State Operating Permit No. V11-021 issued May 13, 2013 and AMS Plan Approval 06167A, dated 3/11/13. The baseline NOx emissions are 145.02 tons pe r year for each Boiler No. 1 & No.2 [283 mmbtu/hr *8760 hr/yr * 0.39 lb/MMBTU *0.3= 145.02 tons per year].

The following NOx controls were determined technologica lly feasible for Boilers #1 & #2: ULNB, ULNB with NG, FGR, and LNB. The table below provides a summary of co st-effectiveness of each control on each boiler. For more details, refer to the Appendix.

Source Control Technology NOx Emissions (tons per year) NOx

Reduction (%) NOx

Reduction (tpy) Total

Annualized Cost ($/y) Cost

Effectiveness ($/Ton)

Edison

Boilers ULNB 145.02 30 43.50 $981,486 22,563 ULNB with NG 145.02 62 89.91 $1,995,437 22,194 FGR 145.02 40 58 $1,124,514 19,388 LNB 145.02 20 29 $998,340 34,426

The controls evaluated were determined economically unreasonable for Boilers #1 and #2.

Although no additional RACT controls reasonable, the existi ng 30% capacity factor limit for each boiler #1 & #2 is more stringent than the current SIP-approved RACT limit on an annual basis. Thus, to further reduce NOx emissions AMS is proposing to incorporate as RACT a 145.02 tons per 12-month rolling NOx emissions limit based on the 30% capacity factor for boilers 1 and 2 and the 0.39 lb/MMBTU limit.

Currently allowed RACT emissions: 619.77 tons per rolling of 12 months Proposed allowed RACT emissions: 145.02 tons per rolling of 12 months

Boilers #3 and #4:

Boiler #3 and Boiler #4 each has a NOx emission limit of 0.50 lbs/MMBTU from the 1-hour RACT determination,

now the emission limitation reduced to 0.38 lbs/MMBTU. AMS has determined the new lbs/MMBTU limits to be RACT because stack test data has shown the boilers can comply with these limits under existing technology. Each boiler has a Federally enforceable annual 30% capacity limit based on hourly maximum heat input, as listed in Section D. 2 (a)(1) established in Title V/State Opera ting Permit No. V11-021 issued May 13, 2013 and AMS Plan Approval 06167A, dated 3/11/13. The baseline NOx emissions are 167.28 tons per year for Boilers No. 3 & No.4[335 mmbtu/hr *8760 hr/yr *0.38 lb/MMBTU *0.3= 167.28 tons per year]. Boilers #3 & #4 will be more stringent than the current SIP approved limit on an annual basis By taking the limit based on the 30%. Currently allowed RACT emissions: 733.67 tons per rolling of 12 months Proposed allowed RACT emissions: 167.28 tons per rolling

of 12 months.

The following NOx controls were determined technologica lly feasible for Boilers #3 & #4: ULNB, ULNB with NG, FGR, and LNB. The table below provides a summary of co st-effectiveness of each control on each boiler. For more details, refer to the Appendix.

Source Control Technology NOx Emissions (tons per year) NOx

Reduction (%) NOx

Reduction (tpy) Total

Annualized Cost ($/y) Cost

Effectiveness ($/Ton)

Edison

Boilers ULNB 167.28 30 50.18 $981,486 19,559 ULNB with NG 167.28 62 103.71 $1,995,437 19,241 FGR 167.28 40 66.91 $1,124,514 16,806 LNB 167.28 20 33.46 $998,340 29,837

The controls evaluated were determined economically unreasonable for Boilers #3 and #4.

Although no additional RACT co ntrol is reasonable, the existing 30% capac ity factor limit for each of boilers #3 & #4 is more stringent than the current SIP-approved RACT limit on an annual basis. Thus, to further reduce NOx emissions AMS is proposing to incorporate as RACT a 167.28 tons per 12-month rolling NOx emissions limit based on the 30% capacity factor for Boilers 3 and 4.

By taking this restriction on Boilers #1,#2, #3, and #4, the total potential emissions from Boilers #1,#2, #3, and #4 (624.56 tons per year) are:

A. Less than the existing combined emissions limit of 2,195 tons in any rolling 12-month period. These combined limits are greater than the potential emissions of the boilers. AMS proposes that these combined limits cannot continue to represent RACT for the boile rs as a result the combined emissions limit of 2,195 tpy is being removed.

B. Less than the existing combined fuel usage limit of 65,526,316 gal/yr potential emissions of the boilers to 1539.8 tons per 12-month rolling (65,526,316 gal/yr * 47 lbs/10 3 gal * 1 ton/2000 lbs= 1539.8 tons per rolling 12 months) period. These combined limits are greater than the potential emissions of the boilers. AMS proposes that these combined limits cannot continue to represent RACT for the boilers as a result the combined the combined fuel limit is being removed.

Monitoring & Recordkeeping

The facility shall monitor and record compliance with them based on fuel usage and the annual NOx stack tests. The facility shall maintain a file containing all the records and ot her data that are required to be collected to demonstrate compliance with NOx RACT requirements of 25 PA Code §129.91-129.94.; including monthly records of fuel consumption, fuel sulfur content, and NOx emissions.

Conclusions and Recommendations: AMS is replacing the 0.50 lbs/MMBTU NOx limit for each boiler with the following NOx limits: 0.39 lbs/MMBTU and110.37 lbs/hr for Boilers #1 and #2 (each) and 0.38 lbs/MMBTU and 127.3 lbs/hr for Boilers #3 and #4 (each).

The lbs/hr limits were determ ined using the new lbs/MMBTU limits and the rated capacities of the boilers. AMS is determining the 145.02 tons of NOx per rolling 12-month period emission limit for Boiler #1 and Boiler #2 and the 167.28 tons of NOx per rolling 12-month period emission limit for Boiler #3 and Boiler #4 as an additional RACT requirement. AMS requests these limits to be approved in to the SIP. Also, AMS requests to remove the combined NOx emissions limit and a combined fuel limit for Boilers #1, #2, #3, #4. AMS recommends that these updates to the NOx RACT requirements currently approved in the SIP for the 1-hour ozone standard represent NOx RACT for

the 1997 8-hour ozone standard for Veolia Edison.1 / 9 / 1 5

Edward Wiener, Chief of Source Registration Date

Appendix

Detail Calculations Summary

The following costs are calcula ted in order to evaluate the cost effectiv eness of each emission control technology:

‐ Total Capital Investment (TCI)

‐ Direct Annual Cost (DAC) ($/yr)

‐ NOx Emission Reduction (tons/yr)

‐ Cost Effectiveness ($/ton)

o Capital Recovery = Convert from P (present Value) to A(Annual amount), A=P(A/P,i%,n),



### 1 ) 1 ( ) 1 (

  



n n



### i i i CR 20% interest and 10 yrs = A/P=0.2385

Where i= Annual interest Rate; n= control system life; Annual Cost = TCI x CRFVEOLIA EDISON (Boilers #1, #2, #3, and #4)

Table 1- Detailed Calculations for Veolia-Edison Boilers (Boiler #1,2, 3, & 4) for ULNB

Veolia Edison Data Capacity Factor =30% Boilers Capacity 283 mmbtu/hr

335 mmbtu/hr

Total capital Cost

Total Capital Investment Cost (TCI) $3,025,835 TCI from 1-hour RACT proposal plus inflation adjustment. Original TCI includes equipment cost estimates from Riley Stoker Corp. and installation cost estimates from JACA Corp 4

. Capital Recovery $721,662 10 yrs @20% -from 1 hr RACT

CRF= 0.2385 Annual Operating Costs

Direct Annual Cost Electricity Cost 2 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr Operator 3 $16,425 0.5hr/shift, 3 shift/day, $30/hr Supervisor 3 $2,463.75 15% of Operator

Maintenance 3 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material 3 $19,162.50 100% of Maintenance

Total Direct Annual Cost $ 127,294

Indirect Annual Cost

Overhead 3 $11,497 60% of maintenance-OAQPS 1
Administrative Charge 3 $60,517 2% of TCI-OAQPS 1

Property Taxes 3 $30,258 1% of TCI-OAQPS 1

Insurance 3 $30,258 1% of TCI-OAQPS 1

Total Indirect Annual Cost $132,531

Total Annual Operating Costs $981,486

NOx Baseline Emissions (TPY) B#1 & 2 =145.02

B#3 &4 = 167.28 B#1 & 2 = 283 mmbtu/hr *8760 hr/yr * 0.39 lb/MMBTU *0.3=145.02 tpy B#3 &4 = 335 mmbtu/hr *8760 hr/yr * 0.38 lb/MMBTU *0.3= 167.28 tons per

year NOx Emission Reduction (TPY) B#1 & 2 = 43.50 tpy B#3 &4 = 50.18 tpy Assumed 30% NOx removal.

Cost Effectiveness ($/ton NOx $22,563 (B #1 )removed) $19,559 (B #3 )

Table 2 Detail Calculations for Exelon Edison Boiler ULNB with NG

Veolia Edison Capacity Factor =30%

Turbine Capacity Boiler 1&2=283 MMBTU/hr &

Boiler 3 & 4 =335 MMBTU/Hr

Total capital Cost

Total Capital Investment Cost (TCI) $3,326,735 For NG Line

construction from PGW $3.9 million TCI from 1 hr RACT proposal plus inflation adjustment. Original TCI includesequipment cost estimates from vendorsupplied estimates for similar units or industry data gathered for similar projects and new pipeline from PGW. TCI with NG Line $7,226,735 $3,900,000

Capital Recovery $1,723,576 0.2385 10 yrs @20% -from 1 hr RACT Annual Operating Costs

Direct Annual Cost

Electricity Cost 2 $70,080 100kw @ $0.08/kwh, 8760 hrs/yr

Operator 3 $16,425 0.5hr/shift, 3 shift/day, $30/hr

Supervisor 3 $2,463.75 15% of Operator

Maintenance 3 $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material 4 $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost

Overhead 3 $11,498 60% of maintenance-OAQPS 1

Administrative Charge 3 $66,535 2% of TCI-OAQPS 1

Property Taxes 3 $33,267 1% of TCI-OAQPS 1

Insurance 3 $33,267 1% of TCI-OAQPS 1

Total Indirect Annual Cost $144,567

Total Annual Operating $1,995,437Costs

NOx Emission Reduction (TPY) 89.91 103.71 boiler #1 &2=89.91 ; Boiler #3 

=103.71 Cost Effectiveness ($/ton NOx removed) $22,194 $19,241

Table 3 Detail Calculations for Veolia Edison Boiler FGR

Veolia Edison Data Capacity Factor =30% Boilers Capacity 2 x 283 mmbtu/hr

2 x 335 mmbtu/hr Total capital Cost Total Capital Investment Cost (TCI) $3,539,400 TCI from 1-hour RACT proposal plus inflation adjustment. Original TCI includes cost estimates from Riley Stoker Corp. and JACA Corp. Capital Recovery $844,147 10 yrs @20% -from 1 hr RACT

Annual Operating Costs

Direct Annual Cost Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr Supervisor $2,463.75 15% of Operator Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr Material $19,162.50 100% of Maintenance

Total Direct Annual Cost $ 127,294

Indirect Annual Cost Overhead $11,497 60% of maintenance-OAQPS 1
Administrative Charge $70,788 2% of TCI-OAQPS 1
Property Taxes $35,394 1% of TCI-OAQPS 1
Insurance $35,394 1% of TCI-OAQPS 1

Total Indirect Annual Cost $153,074

Total Annual Operating Costs $1,124,514

NOx Emission Reduction (TPY) B#1 & 2 = 58 tpy B#3 &4 = 66.91 tpy Cost Effectiveness ($/ton NOx removed) $19,388 (B #1 ) $16,806 (B #3 )Table 4 Detail Calculations for Veolia Edison Boiler LNB

Veolia Edison Capacity Factor =30%

283 MMBTU/hr &335 MMBTU/Hr

Total capital Cost

Total Capital Investment Cost (TCI) $3,086,352 TCI from 1 hr RACT proposal plus inflation adjustment. Original TCI includes equipment cost estimates from vendor-supplied estimates for similar units or industry data gathered for similar projects. Capital Recovery $736,095 0.2385 10 yrs @20% -from 1 hr RACT Annual Operating Costs

Direct Annual Cost

Electricity Cost $70,080 100kw @ $0.08/kwh, 8760 hrs/yr

Operator $16,425 0.5hr/shift, 3 shift/day, $30/hr

Supervisor $2,463.75 15% of Operator

Maintenance $19,162.50 0.5hr/shift, 3 shift/day, $35/hr

Material $19,162.50 100% of Maintenance

Total Direct Annual Cost $127,294

Indirect Annual Cost

Overhead $11,498 60% of maintenance-OAQPS 1

Administrative Charge $61,727 2% of TCI-OAQPS 1

Property Taxes $30,864 1% of TCI-OAQPS 1

Insurance $30,864 1% of TCI-OAQPS 1

Total Indirect Annual Cost $134,952

Total Annual Operating

Costs $998,340

NOx Emission Reduction (TPY) 29 33.46 boiler #1 &2= 29; Boiler #3 

=33.46 Cost Effectiveness ($/ton NOx removed) $34,426 $29,837References

1. Office of Air Quality Planning and standards ( OAQPS) Environmental Protection Agency (EPA) Air Pollution Control Manual, Six Edition, EPA/452/B-02-001, January 2002.

2. Electricity cost: EPA cost calculation, Appendix A-NOx Control Analysis

3. North East States for Coordinated Air Use Management (NESCAUM)

4. http://new.abb.com/power-generation